Justia Idaho Supreme Court Opinion Summaries

In the early morning of January 8, 2021, two individuals dressed in black entered Samuel Johns' residence. Patrycia Labombard, a visitor, witnessed one of the assailants armed with a handgun and described one as a young woman. Labombard was restrained with zip ties but managed to hide in the bathroom. She heard a fight, gunshots, and then the assailants leaving. Johns was found with gunshot wounds and later died. Police interviews with witnesses and family members pointed to Clyde Ewing and his son Demetri as suspects, motivated by a dispute over a stolen pistol and backpack. Evidence collected included surveillance footage, physical evidence from the crime scene, and items found in the suspects' motel room.The District Court of the Second Judicial District of Idaho charged Clyde with first-degree felony murder. Clyde filed motions to dismiss based on his right to a speedy trial, which were denied by the district court, citing COVID-19 related delays as good cause. The court also admitted a video interview of a deceased witness and a compilation video prepared by a police officer, despite Clyde's objections. Clyde was found guilty by a jury and sentenced to life in prison without parole.The Supreme Court of Idaho reviewed the case and affirmed the district court's judgment. The court held that the COVID-19 pandemic constituted good cause for trial delays, thus not violating Clyde's right to a speedy trial. The court also found that while the admission of the deceased witness's video interview violated the Confrontation Clause, the error was harmless given the overwhelming evidence against Clyde. Additionally, the court ruled that the compilation video was properly admitted as it summarized voluminous recordings that could not be conveniently examined in court. The cumulative error doctrine did not apply as only one error was identified, which was deemed harmless. View "State v. Ewing" on Justia Law

In the early morning of January 8, 2021, two individuals dressed in black entered Samuel Johns' residence. Patrycia Labombard, a visitor, saw the intruders, one of whom was armed with a handgun. She described one as a teenaged girl or young woman. Labombard was restrained with a zip tie but managed to escape and hide. She heard a fight, yelling, and gunshots. After the intruders left, she found Johns with gunshot wounds. Johns died from his injuries. Police interviewed witnesses, including Johns' mother, Debra Moffat, and family members who suspected Clyde Ewing and his son, Demetri Ewing, due to an ongoing dispute over a stolen pistol and backpack. Surveillance footage showed two individuals on bikes near Johns' house. Clyde and Demetri were arrested, and a search of their motel room revealed incriminating evidence.The District Court of the Second Judicial District of Idaho denied Demetri's motion to suppress evidence obtained from the search and arrest warrants, finding probable cause. The court also admitted statements from Moffat, who had died before trial, over Demetri's hearsay objections. Demetri was found guilty of first-degree felony murder and sentenced to life in prison with 25 years fixed.The Supreme Court of Idaho reviewed the case. The court affirmed the district court's denial of Demetri's motion to suppress, finding sufficient probable cause for the search and arrest warrants. The court also found that Demetri was not entitled to a Franks hearing, as he failed to show that any omissions or misstatements in the warrant affidavits were made intentionally or recklessly. However, the court agreed that admitting Moffat's statements violated the Confrontation Clause but concluded that this error did not affect the trial's outcome due to the substantial evidence against Demetri. The Supreme Court of Idaho affirmed the district court's judgment of conviction. View "State v. Ewing" on Justia Law

Kevin Keith Bell was convicted of rape, witness intimidation, and felony domestic battery. He filed a pro-se petition for post-conviction relief, alleging prosecutorial misconduct, actual innocence, and ineffective assistance of counsel. Bell later filed an amended petition through counsel, focusing on three specific instances of ineffective assistance of counsel. The State moved for summary dismissal of the amended petition, which the district court granted. Bell then filed a motion for reconsideration, arguing the district court erred in dismissing his amended petition on grounds not raised by the State. The district court denied the motion.The district court of the Fifth Judicial District of Idaho initially handled Bell's case. After the State moved for summary dismissal, the district court granted the motion, finding Bell had not provided sufficient legal argument to support his claims of ineffective assistance of counsel. Bell's motion for reconsideration was also denied, as the district court concluded that the State had indeed argued the grounds for dismissal and that Bell had failed to demonstrate a genuine issue of material fact.The Supreme Court of the State of Idaho reviewed the case. The court held that Bell failed to preserve his argument regarding the lack of notice for the dismissal of his original claims because he did not raise this issue in his motion for reconsideration. The court also affirmed the district court's dismissal of Bell's claim that his trial counsel was ineffective for failing to inquire into an allegedly biased juror, as Bell did not provide sufficient evidence of actual bias or resulting prejudice. Consequently, the Supreme Court affirmed the district court's judgment dismissing Bell's petition for post-conviction relief. View "Bell v. State" on Justia Law

Trevor Leon Moore pleaded guilty to misdemeanor battery, and the magistrate court entered an order withholding judgment, which included a requirement for Moore to complete a domestic violence evaluation. Moore objected to this requirement, arguing it was improper since he pleaded guilty to simple battery, not domestic battery. The magistrate court's order was file stamped on December 14, 2023, and Moore filed a notice of appeal to the district court on January 26, 2024, challenging only the evaluation requirement.The district court addressed the intermediate appeal and affirmed the magistrate court's order, including the disputed requirement. Moore then filed a timely notice of appeal to the Supreme Court of Idaho.The State filed a motion to dismiss Moore's appeal, arguing that his notice of appeal from the magistrate court to the district court was untimely, rendering the district court's decision void. The Supreme Court of Idaho agreed that the district court's decision was void due to the untimely appeal but clarified that it still had jurisdiction to review the district court's decision. The court held that it could not grant Moore the relief he sought because the district court lacked subject matter jurisdiction to grant any relief on intermediate appeal.The Supreme Court of Idaho vacated the district court's decision, dismissed the appeal to the Supreme Court, and remanded the case to the district court with instructions to dismiss Moore's intermediate appeal as untimely. View "State v. Moore" on Justia Law

Claudia Horn worked for Insure Idaho, LLC for over six years and signed a non-solicitation agreement prohibiting her from soliciting Insure Idaho customers. After leaving Insure Idaho to work for Henry Insurance Agency, LLC, several Insure Idaho customers followed her. Insure Idaho sought a preliminary injunction to prevent Horn and Henry Insurance from soliciting its customers, which the district court granted. The district court later found Horn in contempt for violating the preliminary injunction when another former Insure Idaho customer moved its business to Henry Insurance.The district court granted the preliminary injunction and found Horn in contempt, but did not impose any sanctions. Henry Insurance was dismissed from the contempt proceedings and awarded attorney fees. Horn appealed the contempt judgment, and both Henry Insurance and Insure Idaho cross-appealed.The Supreme Court of Idaho reviewed the case and determined that the district court erred in finding Horn in contempt, as it lacked the ability to impose any sanction. The court also found that the district court misinterpreted the term "solicitation" and that Horn's actions did not constitute solicitation under the plain meaning of the term. The court held that the district court abused its discretion by granting the preliminary injunction without adequately addressing whether Insure Idaho was likely to succeed on the merits of its claims.The Supreme Court of Idaho reversed the judgment of contempt, vacated the preliminary injunction, and remanded the case for further proceedings. The court affirmed the district court's dismissal of Henry Insurance from the contempt proceedings and awarded attorney fees to Henry Insurance. The court also awarded Horn attorney fees for the contempt trial and appellate attorney fees for both Horn and Henry Insurance. View "Insure Idaho v. Horn" on Justia Law

The Idaho Legislature established the Community Partner Grant Program in 2021, using funds from the American Rescue Plan Act (ARPA) to address the impact of the COVID-19 pandemic on school-aged children. The funds were to be used exclusively for in-person educational and enrichment activities for children aged 5 to 13. In 2023, the Idaho Attorney General received information suggesting that some grant recipients had misused the funds to serve children under the age of five. Consequently, the Attorney General issued civil investigative demands (CIDs) to 34 grant recipients, requesting documentation related to the grant program. The recipients did not comply and instead sought a preliminary injunction in district court to set aside the CIDs.The District Court of the Fourth Judicial District of Idaho denied the preliminary injunction for 15 grant recipients, requiring them to respond to the CIDs, but granted it for 19 others, concluding that the Attorney General had not shown sufficient reason to believe these recipients had misused the funds. The court also reviewed two declarations in camera and provided redacted versions to the recipients' counsel.The Supreme Court of Idaho reviewed the case and held that both the Idaho Charitable Assets Protection Act (ICAPA) and the Idaho Charitable Solicitation Act (ICSA) applied to the grant funds, giving the Attorney General authority to issue CIDs. The court determined that the "reason to believe" standard, not probable cause, was sufficient for issuing CIDs. The court found that the district court erred in granting the preliminary injunction to the 19 recipients and remanded the case for further proceedings. Additionally, the court held that the CID issued to Elizabeth Oppenheimer was overly broad and violated her First Amendment right to freedom of association, requiring the district court to reconsider this CID. The court declined to award attorney fees to either party. View "Children's Home Society v. Labrador" on Justia Law

Several local taxing districts within Kootenai County, Idaho, including East Side Highway District, Post Falls Highway District, Worley Highway District, the City of Coeur d’Alene, and the City of Post Falls, filed claims against Kootenai County and its Treasurer, Steven Matheson. The dispute arose when Matheson decided that the County would retain all late charges and interest from delinquent property taxes to cover collection costs, rather than distributing a proportionate share to the taxing districts. The taxing districts argued that they were entitled to their share of these funds.The District Court of the First Judicial District of Idaho ruled in favor of the taxing districts, granting their motions for summary judgment and judgment on the pleadings. The court determined that Idaho Code sections 63-1015 and 63-1007(1) required the County to distribute the late charges and interest proportionately to the taxing districts. The court also awarded attorney fees to the taxing districts under Idaho Code section 12-117(4).The Supreme Court of the State of Idaho reviewed the case and affirmed the district court's judgment. The Supreme Court held that the statutory language was unambiguous and required the County to apportion late charges and interest among the taxing districts in the same manner as property taxes. The Court also upheld the award of attorney fees to the taxing districts, noting that Idaho Code section 12-117(4) mandates such an award in cases involving adverse governmental entities. The Supreme Court awarded attorney fees and costs on appeal to the taxing districts. View "East Side Hwy Dist v. Kootenai County" on Justia Law

The case involves a dispute over the interpretation and application of Idaho Code section 63-602G, which governs the homestead property tax exemption. In 2020, the Idaho Legislature amended the statute to remove the April 15 application deadline and added that the exemption "shall be effective upon the date of the application." The Idaho State Tax Commission issued guidance stating that the exemption should not be prorated based on the application date, which was supported by an Attorney General Opinion. However, Latah and Lincoln Counties disagreed and prorated the exemption based on the application date.The Counties petitioned for judicial review in their respective district courts, which were consolidated. The district court ruled in favor of the Counties, determining that the Tax Commission exceeded its authority and that the statute was ambiguous, allowing for proration based on legislative intent. The Tax Commission appealed the decision.The Supreme Court of Idaho reviewed the case and held that the plain language of Idaho Code section 63-602G requires the retroactive application of the homestead exemption to January 1 of the tax year during which the application was submitted, regardless of the application submission date. The Court found that the statute was unambiguous and that the exemption applies to the entire tax year, not prorated based on the application date.The Court also determined that the Tax Commission did not exceed its statutory authority when it issued the May 2022 Order directing the Counties to apply the full homestead exemption. The Court concluded that the Tax Commission's order was within its constitutional and statutory powers to ensure uniformity and compliance with property tax laws.The Supreme Court of Idaho reversed the district court's order, vacated the judgment, and remanded the case for entry of an order affirming the Tax Commission’s May 2022 Order. View "Latah County v. Idaho State Tax Commission" on Justia Law

Damon Victor Crist was convicted of first-degree kidnapping in Utah in 2006 and was required to register as a sex offender in Utah. In 2022, Crist began working in Idaho but did not register as a sex offender there. An informant tipped off the Idaho State Police (ISP), leading to Crist's arrest for failing to register. Crist argued that Idaho law did not permit the magistrate court to determine that his Utah conviction was substantially equivalent to Idaho’s second-degree kidnapping law, which would require him to register. He also claimed that the statutory scheme was void for vagueness.The magistrate court found probable cause to bind Crist over for trial, determining that his Utah conviction was substantially equivalent to an Idaho registrable offense. Crist filed a motion to dismiss in the district court, arguing that only the ISP’s Bureau of Criminal Identification could make the substantial equivalency determination and that he lacked proper notice of his duty to register. The district court denied his motion, concluding that the magistrate court had the authority to make the determination and that Crist had sufficient notice of his registration requirements.The Supreme Court of Idaho affirmed the district court's decision. The court held that a nonresident’s duty to register as a sex offender in Idaho is triggered by the fact of an out-of-state conviction that is substantially equivalent to an Idaho registrable offense and entry into Idaho for employment purposes. The court also concluded that the statutory and regulatory scheme provided fair notice to Crist and did not grant law enforcement unbridled discretion. Therefore, Crist's arguments were rejected, and the decision of the district court was affirmed. View "State v. Crist" on Justia Law

Mark Radford and the State Board of Land Commissioners and the Idaho Department of Lands (collectively, "the State") were involved in a contract dispute over the State's easement on Radford's property. The State used the easement to access and manage state endowment lands leased for grazing. Historically, the State accessed the easement through the Hallo Property, which Radford purchased in 2020, subsequently revoking the State's access. Radford claimed that an email from the State indicated the easement was no longer needed, leading him to file a lawsuit alleging the State breached the termination clause of the easement agreement by not providing a statement confirming termination.The District Court of the Seventh Judicial District of Idaho granted summary judgment in favor of the State, determining that the termination clause gave the State sole and subjective power to decide whether the easement was necessary. The court found that the State had not made any determination that the easement was no longer needed, thus dismissing Radford's breach of contract claim. Radford appealed the decision.The Supreme Court of the State of Idaho reviewed the case and affirmed the district court's decision. The court held that the State had no contractual duty to assess whether the easement was necessary for its granted purposes. The agreement's termination clause did not impose an obligation on the State to periodically reassess the easement's necessity. The court also rejected Radford's argument that the State's refusal to terminate the easement violated the covenant of good faith and fair dealing, as the State had not determined the easement was no longer needed. The court awarded attorney fees and costs on appeal to the State, concluding that Radford's appeal was unreasonably pursued. View "Radford v. Van Orden" on Justia Law